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V0456-26 ·27 February 2026 ·consulta-vinculante Medium impact
Tax

Special tax regime requires relocation to be linked to becoming an entity administrator

An Israeli national inquired whether moving to Spain for an Israeli business project would allow access to the special tax regime under Article 93 of the Spanish Income Tax Law. The DGT states that a causal link must exist between the move and the acquisition of administrative status in the entity.

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2026-02-27PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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